Brown v. Johnson’s Empirical Analysis
1995
Citation profile
1 district ·
Relationships
Applies 18 U.S.C. § 224 · 26 U.S.C. § 7422 · 26 U.S.C. § 7432 · 26 U.S.C. § 7433 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 2410 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics · Bush v. Lucas · Chappell v. Wallace · Schweiker v. Chilicky · McMillen v. United States Department of Treasury
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Today these rights include, in addition to the right to sue for a tax refund under 28 U.S.C. § 1346 (a)(1) and 26 U.S.C. § 7422 , and the ability to contest the validity of tax liens under 28 U.S.C. § 2410 , the remedies enacted in the “Taxpayer Bill of Rights.” When they are deployed in their proper time and place ... these remedies enable an aggrieved taxpayer to recover damages for the sorts of abuses alleged here: the wrongful failure to release tax liens, 26 U.S.C. § 7432 , and the reckless or intentional violation of any provision of the tax laws “in connection with any collection of Federal tax----” Congress has deemed Sections 7432 and 7433 the exclusive remedies for damages resulting from such abuses. The remedies Congress has created may not be perfectly comprehensive, but they do supply “meaningful safeguards or remedies for the rights of persons situated” as the [plaintiffs] were and establish “that Congress has provided what it considers adequate remedial mechanisms for constitutional violations that may occur in the [administration of the tax laws.]” In such cases, the courts have declined to create new Bivens remedies.”
1 later decision quote this exact passage · from the majority“If, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally disregards any provision of this title, or any regulation promulgated under this title, such taxpayer may bring a civil action for damages against the United States in a district court of the United States. Except as provided in section 7432, such civil action shall be the exclusive remedy for recovering damages resulting from such actions.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.